Quantcast Summary of Comments and Agency's Response - epafirm0069

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for stability,, and a secondary backing made of PVC, polyurethane, or other hardback
material is applied. Finally, the carpet is cut into squares, usually 18" x 18".
The majority of carpet manufactured in the U.S. is made of nylon carpet fibers, with
a smaller percentage (about 10 percent) being made of polyester. Commenters provided
information on the market share for various carpet fiber types. The market share for carpet
fiber is approximately as follows: 67 percent nylon, 23 percent polypropylene, 10 percent
polyester, and 1 percent wool.
At this time, EPA is not aware of any carpet fibers other than polyester that are
manufactured with postconsumer recovered materials. Several major nylon fiber.
manufacturers commented that they have initiated programs to recover used carpets from the
waste stream and reprocess the nylon into new products. As these programs mature, there
may be a supply of postconsumer nylon that will be suitable for the manufacture of new
nylon carpet fiber. Some commenters stated that they currently reuse nylon fiber scrap in
their manufacturing process. However, the commenters did not make it clear whether this
scrap would be considered preconsumer material or "rework" material normally reintroduced
in the manufacturing process. Further, even if this nylon fiber scrap would be considered
preconsumer material, it appears that it is a standard industry practice to incorporate this
material into the manufacturing process as a normal business practice to reduce raw material
costs. It does not appear that these materials are truly being diverted from disposal. Thus,
designating nylon carpet at this time would have little impact on diverting waste materials
from disposal. Further, no commenters provided information on the percent of preconsumer
nylon fiber contained in their products.
2. Summary of Comments and Agency's Response
a. Performance. Several commenters were concerned about the proposed designation
of polyester carpet, stating that this item generally does not meet the performance standards
for commercial applications, Commenters stated that nylon carpeting is preferred in
commercial applications because of the fiber's superior performance characteristics, while .
polyester carpeting is mainly suited for low-wear or residential applications. Another
commenter stated that nylon fibers can be made in a loop pile construction, whereas
polyester fibers are typically made in a cut-pile construction which is prone to faster wear.
EPA is aware that polyester carpeting may not perform as well as nylon carpeting in
high-wear and severe-wear applications. For this reason, EPA proposed to. designate
polyester carpet for low- and medium-wear applications only. The designation of polyester
carpet applies only in those cases where procuring agencies have determined that polyester
carpet has suitable performance characteristics to meet the agencies' particular applications.
Where it is determined that polyester carpet is suitable, procuring agencies should purchase
polyester carpet containing recovered materials.
b. Scope of designation. Several commenters believed that the terms "low and
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